Authored by Amber Kadamilakis and Skye Mc Mahon.
The Companies and Intellectual Property Commission (CIPC) has signalled a clear shift toward active enforcement of beneficial ownership compliance. Under the General Laws (Anti-Money Laundering and Combating Terrorism Financing) Amendment Act, 2022 and the amended Companies Regulations, the CIPC is mandated to collect and maintain beneficial ownership information for all registered entities. The aim is to promote transparency around the natural persons who ultimately own or control companies and to prevent the misuse of corporate structures for money laundering, terrorist financing, and other illicit activities.
On 29 July 2026, the CIPC issued Notice 36 of 2026 noting that the CIPC will being conducting beneficial ownership inspections to verify the accuracy and completeness of beneficial ownership information submitted. Notices of these inspections have already been issued to companies, and some inspections have already been completed.
Inspection process
The inspection process itself is relatively straightforward:
- inspections are carried out by a minimum of two appointed inspectors;
- at least 50% of the directors of the company must be in attendance. The responsibility to attend cannot be delegated to consultants, company secretaries, or other representatives;
- consultants, company secretaries, or other representatives may attend the inspection;
- the company must have copies of the relevant documentation including their beneficial ownership filings, securities registers, beneficial interest registers, shareholding structures, director registers, and supporting documentation identifying ultimate beneficial owners.
If there are any anomalies identified within the inspection process, the CIPC will issue a report to the company setting out the anomalies that the company must rectify. The report is signed by the CIPC inspectors, and must be countersigned by the company and returned to the CIPC. The company will then have a period of three business days from the date of return of the countersigned report to the CIPC to file a corrected beneficial ownership filing with the CIPC.
Additional considerations
- It is important to ensure that the CIPC’s records in relation to the company’s board are up to date and correct. This allows the CIPC to confirm that the appropriate persons are in attendance, and that the required quorum of directors are in attendance.
- The report issued by the CIPC in the event of anomalies on the beneficial ownership filing must be countersigned by each director of the company in attendance at the inspection, but is practically also required to be signed by all other attendees - including third party advisors or consultants.
- The replacement beneficial ownership filing that addresses the issues identified in the report must be filed within a three business day period from the date that the countersigned report is returned to the CIPC. Depending on the nature of the anomalies identified, the availability of information of beneficial owners (which can include offshore persons) is imperative to comply with this short deadline.
- The company will still need to comply with their usual beneficial ownership filing that must be made within 30 business days after the anniversary of the entity as part of their annual compliance obligations.
Despite the CIPC only issuing an acknowledgement when a beneficial ownership filing is made, the filings are considered. Companies should proactively review their beneficial ownership records and ensure that their filings align with the required document form and content. Being inspection-ready is no longer optional — it is a regulatory expectation.